Ethics & Compliance

As we pursue our Mission “to be recognized as a company of dedication, honesty, integrity and service,” Medtronic introduced two global policies during fiscal year 2011 designed to supplement requirements already described in our Code of Conduct and initiated employee training on both.

Global Anti-Corruption Policy

In February, we instituted a written Global Anti-Corruption Policy that will continue to ensure compliance with the requirements of all applicable anti-corruption laws and regulations, including the U.S. Foreign Corrupt Practices Act (FCPA) and anti-corruption laws of other countries in which we or our business partners do business.

The policy provides Medtronic employees and business partners with a clear statement of our standards and expectations prohibiting the payment of bribes or other unethical payments or benefits. No employee nor business partner shall offer, pay, promise to pay, or authorize payment or the giving of money or anything of value – regardless of whether the payment or giving of anything of value is actually made or delivered – to any customer, foreign official, or other third party for the purpose of obtaining any improper business advantage, whether or not such advantage is actually obtained.

Medtronic requires that all payments and other activities covered by this policy be accurately recorded. False, misleading, incomplete, inaccurate or artificial documenting, reporting or recording of payments or activities is strictly prohibited.

Our Chief Ethics and Compliance Officer is responsible for administering and interpreting this policy under the oversight of the Audit Committee of our Board of Directors.

In conjunction with the rollout of this policy, Medtronic expanded its global anti-corruption training and provides both online and live courses worldwide. Currently annual classroom training is required for individuals outside of the United States who interact with our international customers and those working in functions that support interactions and transactions with customers, such as sales, marketing, customer support and finance. The requirement extends to distributors and/or agents doing business outside of the United States on behalf of Medtronic. Classroom training is supplemented by online courses. We track completion of both online and classroom training in our learning management system.

Global Conflicts of Interest Policy

Medtronic also launched a new global Conflicts of Interest Policy in December 2010. Applicable to all Medtronic employees and officers worldwide, the policy prohibits engaging in activities that create a conflict between their personal interests and the legitimate business interests of the company.

Designed to supplement information already available in our Code of Conduct, the policy provides employees with practical guidance on how to avoid or disclose real or potential conflicts of interest with business partners, suppliers, vendors and colleagues.

Details of the policy – such as guidelines on business-related meals, travel and entertainment; prohibited gifts; use of company property; outside employment or service on a board of directors; and personal investments – are accessible on the company intranet, along with appropriate disclosure procedures.

Training on the new policy is incorporated in our annual Code of Conduct training, which is required for all U.S. and Puerto Rico employees.

To learn more about our management approach to Ethics and Compliance, please read our 2010 report.